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Letter to Gary Locke, Secretary of the Department of Commerce


Location: Unknown

The Honorable Gary Locke
Department of Commerce
1401 Constitution Ave., NW
Washington, DC 20230

Dear Secretary Locke:

The recreational fishing public and associated businesses are once again facing a looming regulatory crisis in the recreational black sea bass fishery. The Mid-Atlantic Fishery Management Council (MAFMC) is considering a 44 percent reduction in recreational landings based on projections, assumptions and guesswork using Marine Recreational Fisheries Science Survey (MRFSS) data. I am writing to request your immediate, personal attention to this matter so that a socio-economic crisis can be averted and we can help regain some of the public trust that has been lost in fisheries management of late.

I request your support for setting the 2011 total allowable landings (TAL) at 4.96 million pounds with a corresponding total allowable catch (TAC) of 5.86 million pounds for the black sea bass fishery to help offset the looming socioeconomic impacts on the recreational sector. The National Marine Fisheries Service (NMFS) has proposed specifications for the 2011 black sea bass fishery and can still ensure the final regulations reflect the need to sustain a fully rebuilt stock while also protecting the local economies that depend on this fishery.

As you are aware, the most recent black sea bass stock assessment, deemed to be the best available science, finds that the stock is not experiencing overfishing and has been rebuilt since 2002. The collective body of scientific information clearly indicates the black sea bass stock continues to remain above the rebuilding target. Unfortunately, the recreational fishing public and fishery dependent businesses continue to be disadvantaged due to inaccurate and unreliable landings data acquired through the much maligned MRFSS.

The problems with MRFSS have been well documented by the National Research Council and others over the last decade. Congress sought to address these problems four years ago via the 2006 amendments to the Magnuson-Stevens Act (MSA). Congress recognized the importance and urgency of improving recreational data collection programs in § 1881(g) of the MSA and established a January 1, 2009 deadline to make the critical improvements. NMFS failed to meet this deadline and despite total appropriations of $18.7 million FY 2008 thru FY 2010 for the MRIP program, the recreational fishing public continues to be regulated in reliance upon the same MRFSS that was being used four years ago. This is unacceptable.

In order to achieve a 44 percent reduction, the MAFMC is considering implementing truly drastic measures such as reducing the black sea bass recreational possession limit from 25 to 1 fish or cutting the season down from what was traditionally 12 months to 4 months when the public has fished sustainably for black sea bass year-round for a number of years. NMFS has a long way to go toward building goodwill with the recreational fishing public and these proposed cutbacks in a healthy fishery will only make that job harder looking ahead.

Based on the rebuilt status of the black sea bass stock and the agency's continued reliance on the discredited MRFSS, I request that NMFS set a 2011 total allowable landings (TAL) at 4.96 million pounds with a corresponding TAC of 5.86 million pounds for the black sea bass fishery to help offset the looming socioeconomic impacts on the recreational sector. This proposed TAC represents the mean TAC for the years 2002 through 2009, the timeframe when the black sea bass was declared rebuilt. A 5.86 million pound TAC is also in line with the Science and Statistical Committee's recommendation to maintain a constant catch approach for this fishery. A 5.86 million pound TAC in 2011 would lessen the impact of the severe regulation reductions currently proposed for the recreational sector. The recreational fishing community should be given reasonable access to this rebuilt fishery and not be punished for the shortcomings of an outdated and flawed data collection system.

Thank you for your attention to this matter. I look forward to hearing your thoughts on this matter in the near future and working with you to ensure our fisheries management actions live up to all the national standards in the MSA.


Member of Congress

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